Manipulation of sports competitions – national platform annual review 2020 Suspicions reported in year two after entry into force of the Federal Act on Gambling’s provisions on competition manipulation Bern, 6 May 2021 1. Introduction By signing the European Council’s Convention on the Manipulation of Sports Competitions1 (Macolin Convention) in 2014, Switzerland has committed itself to cooperation with interna- tional partners in implementing hands-on measures. While coordinating the fight against com- petition manipulation and other political aspects are the responsibility of the Federal Office of Sport, the Federal Act on Gambling2 assigns to the intercantonal authority (previously Comlot, from 1 January 2021 Gespa) the task of a “national platform” acting as reporting office. Gespa as reporting office ensures the flow of information between all parties involved (sports associ- ations, law enforcement authorities, foreign reporting offices, betting operators, etc.) – thus playing a central role when it comes to investigating suspected cases. Sports associations and organisations based in Switzerland that organise, conduct or super- vise a sports event or participate in it are obliged by law to report any suspicion of manipulation to Gespa, provided the event takes place in Switzerland or bets are offered on it in Switzerland (Art. 64(2) Gambling Act). Also the two lottery companies (Swisslos & Loterie Romande) are legally obliged to inform Gespa about suspected manipulation in connection with sports com- petitions on which they offer betting (Art. 64(1) Gambling Act). Depending on the case at hand, Gespa will forward reports to law enforcement or other authorities, lottery companies, sports organisations and reporting offices abroad in accordance with legal requirements. In its role as “Swiss national platform”, Gespa is also a member of the Group of Copenhagen (GoC). The GoC is a network of national platforms and promotes the exchange of information between countries. Various working groups develop tools and processes to continuously im- prove this information flow. Via the online platform of the Danish anti-doping authority (ADD), reports on suspicious activities can be shared easily and safely with the GoC partners. After the Macolin Convention’s taking effect in 2019, a Follow-up Committee consisting of rep- resentatives from Italy, Greece, Norway, Portugal, Moldova, Ukraine and Switzerland began its work in 2020. As representative of the Swiss national platform, Gespa’s Deputy Director formed part of the Swiss delegation at the inaugural meeting of the Committee. In Switzerland, Gespa as reporting office also in 2020 formed the hub for the exchange of information between sports organisations, lottery companies as betting operators, the institu- tions of the Macolin Convention and other international partners, the GoC and law enforcement authorities. Official data on match-fixing is now available in Switzerland for the second time. This report provides a presentation and analysis of the information collected, in particular the suspicion reports received. Gespa makes no claims as to the completeness or methodological sophistication of its analyses. Rather, the aim is to set an example in an area where transpar- ency is an important means of combatting wrongdoing – and to promote a culture where forth- right communication of cases is not taken to indicate widespread delinquency, but is seen as a mark of integrity. No sport is immune from manipulation. By heeding legal reporting obliga- tions, organisations show that they are serious about combatting sports competition manipu- lation. It should be emphasised that reported suspicions do not mean that manipulation has actually taken place. Reports rest on anomalies and irregularities that may be due to manipulation. However, cases of manipulation are usually identified only by combining data and observations from agencies in several countries. Already during Gespa’s initial assessment and triage, many cases (such as sudden significant changes in odds on the betting market) turn out to be 1 SR 0.415.4. 2 BGS, SR 935.51. 1 explicable without the assumption of manipulation (in the case of change in odds, for example by the fact that an important player is out due to injury). 2. Sources of reports In total, Gespa received 125 suspicion reports concerning 97 sports events. This is a sig- nificant decrease compared to the previous year (2019: 263 reports concerning 192 events). The likely reason is the Corona pandemic and the associated cancellations of sports events. The majority of the reports were shared with Gespa by GLMS3 (Global Lottery Monitoring Sys- tem) and the international football governing body FIFA. GLMS filed 49, FIFA 41 reports. Loterie Romande (LoRo) forwarded 8 reports to Gespa in the year under review. Note that the lottery companies fulfil their reporting obligations largely via GLMS and partly via Sportra- dar (see below). GoC partners shared a total of Sources 19 alerts in 2020 via ADD’s online platform mentioned 60 49 above. These included a num- 50 41 ber of reports that were clearly 40 unrelated to Switzerland and 30 therefore did not require any 19 20 action on Gespa’s part. 8 10 4 4 0 FIFA UEFA GLMS Sportradar LoRo GoC Fig. 1: Number of reports by source An important player when it comes to sports statistics and analyses, and thus also to detection of irregularities and suspicious cases in the field of sports betting, is Sportradar, a company also based in Switzerland (St. Gallen). Sportradar has informed Gespa repeatedly about sus- picions in the past. In 2020, there were 4 reports. Another 4 notifications reached Gespa from UEFA. In the year under review, talks were held with UEFA to clear up misunderstandings, and UEFA has declared its unconditional commit- ment to compliance with all federal regulations and the architecture of the Macolin Convention. Against this background, Gespa expects a significantly greater number of reports from UEFA in 2021. The International Olympic Committee (IOC), despite being based in Switzerland and thus subject to the reporting obligation, handed in no reports in 2020. The IOC points out that it invests considerable resources in the fight against competition manipulation. It also operates its own system, the Integrity Betting Intelligence System (IBIS), which is expressly designed to provide information to regulatory authorities and national platforms. In view of the fact that the Olympic Games could not take place in the year under review due to the Corona pandemic, 3 GLMS was founded by European Lotteries (EL) and the World Lottery Association (WLA). It operates a monitoring system with the same name, which has the purpose of detecting and analysing suspicious betting activities. 2 and that just one report was received in the previous year, one may assume that the respon- sible organisational unit of the IOC monitors only its own, i. e. Olympic competitions. It must be emphasised that the legislator allows the reporting of cases for which there is no legal reporting obligation (for example, because no bets can be placed on the relevant event in Switzerland). Especially for Swiss-based international associations who wish to combat ma- nipulation efficiently, Gespa, an institution under public law with an international network, is the point of contact of choice, being able to exchange suspicion reports with competent domestic and foreign authorities, in strict compliance with relevant data protection principles. 3. Overview of reports received See also the tables in the appendix. 3.1 Sport Gespa received suspicion reports in connection with 97 sports events in 2020. Nearly 88% of the reports concerned football (85). Football accounts for by far the largest betting stakes around the globe. The huge number of games on the betting market and the high turnover volume are in themselves important and plausible reasons for the great number of reports. It is an open secret that football is strongly affected by manipulation, but the problem is also being actively combatted. Gespa expressly welcomes FIFA's role in this context. Sport 90 85 80 70 60 50 40 30 20 10 1 1 2 3 1 3 1 0 Basketball Darts Football Handball Ice hockey Snooker Tennis Volleyball Fig. 2: Number of reports by sport Three alerts each were related to ice hockey and tennis. The ice hockey betting market is significantly smaller than that for football. While the sport enjoys little popularity in many countries, the NHL in particular has a certain international ap- peal and is accordingly attractive for betting. As in the previous year, there were relatively few reports pertaining to tennis. Tennis has been struggling with the problem of fixing for a long time for various reasons. For one thing, prize moneys do not cover the costs for the majority of professional athletes. In addition, 3 manipulation in the context of prob betting (e. g. a deliberate double fault or break at a certain score) can be hard to detect and prove. Thus the incentives for and the risk of manipulation are increased. That Gespa nevertheless received only few reports may be due to the following reasons: manipulations are primarily observed at tournaments in the lower ITF categories, on which the Swiss lottery companies – for just this reason – are not allowed to offer bets. Also, the ITF (like the ATP and the WTA) is not based in Switzerland; accordingly, there is no re- porting obligation in this regard. Finally, many smaller ITF tournaments usually held in Swit- zerland could not take place due to the Corona pandemic; in principle, the organisers of such tournaments also have a legal reporting obligation. Basketball (1), handball (2) and volleyball (1) are not as important in Switzerland as are football, ice hockey and tennis, though basketball is fairly popular particularly in the French- speaking part of the country. In regard of the fact that the lottery companies offer a relatively wide range of bets in these sports and that the respective international governing bodies have their headquarters in Switzerland, the number of reports appears to be rather low.